Ericsson (ERIC) ESG Update summary

Leadership and compliance program updates

• Chief Compliance Officer Becky Rohr highlighted her background and recent appointment, emphasizing leadership continuity in compliance and investigations.

• The monitorship and plea agreement with the U.S. Department of Justice, stemming from historical FCPA violations, concluded successfully on June 2, 2024, after certification of anti-corruption compliance by an independent monitor in March 2024.

• All monitor recommendations were implemented, and certifications were provided to the DOJ by senior executives, confirming compliance program effectiveness.

• The monitorship process included multiple review phases, recommendations, and certification steps over four years.

• Ongoing cooperation continues with DOJ and SEC regarding historical conduct related to the Iraq investigation.

Compliance program evolution and culture

• The compliance program now includes hundreds of qualified employees across multiple lines of defense, with a focus on embedding compliance in business operations.

• Senior leaders actively promote ethical culture, with mandatory training, regular communication, and a 'Speak Up' culture reinforcing compliance values.

• Initiatives like the "Behaving with Integrity" goal and integrity conversations are now part of performance reviews.

• Enhanced awareness, training, and risk assessments for high-risk positions have been implemented.

• Digital transformation and data-guided monitoring are key future priorities for compliance.

Program enhancements and strategic priorities

• Compliance policies and tools have been simplified for greater efficiency and user-friendliness, with clarified roles and increased leadership engagement.

• Increased collaboration among assurance functions and a risk-aware decision-making culture have been fostered, breaking down silos.

• Six strategic priorities guide the compliance program: fit for purpose, collaboration, trusted advisor role, accountability, simplification, and digitalization.

• Compliance Office recognized as trusted advisors with business acumen.

• Leaders actively promote accountability and integration of ethics and compliance in decision-making.